Welcome to Scribd, the world's digital library. Read, publish, and share books and documents. See more
Download
Standard view
Full view
of .
Save to My Library
Look up keyword
Like this
0Activity
0 of .
Results for:
No results containing your search query
P. 1
ArrivalStar Et. Al. v. TLX Freight Forward

ArrivalStar Et. Al. v. TLX Freight Forward

Ratings: (0)|Views: 14 |Likes:
Published by PatentBlast
ArrivalStar et. al. v. TLX Freight Forward
ArrivalStar et. al. v. TLX Freight Forward

More info:

Published by: PatentBlast on Mar 30, 2013
Copyright:Attribution Non-commercial

Availability:

Read on Scribd mobile: iPhone, iPad and Android.
download as PDF, TXT or read online from Scribd
See more
See less

03/30/2013

pdf

text

original

 
UNITED STATES DISTRICT COURTSOUTHERN DISTRICT OF FLORIDACase No.ARRIVAL STAR, SA, et al.,Plaintiffs,v.TLX FREIGHT FOWARD, INC.Defendant. ________________________________/
COMPLAINT FOR PATENT INFRINGEMENT
Plaintiffs ArrivalStar S.A. and
Melvino Technologies Limited (collectively “Plaintiffs”),
through their undersigned counsel, hereby sue the above-named defendants for patentinfringement, and in support, allege as follows:
NATURE OF THE LAWSUIT
1.
 
This is an action for patent infringement of United States Patent Numbers:6,714,859; 6,952,645; 7,030,781; 7,400,970; 6,904,359 and 6,486,801; arising under the patentlaws of the United States, Title 35 of the United States Code.
JURISDICTION AND VENUE
2.
 
This Court has subject matter jurisdiction pursuant to 28 U.S.C. § 1331; 28 U.S.C.§ 1338; and 35 U.S.C. § 271.3. This Court has personal jurisdiction over each Defendant pursuant to,
inter alia
,
Florida’s long
-arm statute, § 48.193, in that each Defendant: (a) operates, conducts, engages in,and/or carries on a business or business adventure(s) in Florida and/or has an office or agency inFlorida; (b) has committed one or more tortious acts within Florida; (c) was and/or is engaged in
 
2
substantial and not isolated activity within Florida; and/or (d) has purposely availed itself of 
Florida’s laws, services and/or other benefits and therefore should reasonably anticipate being
hailed into one or more of the courts within the State of Florida.4. Venue is proper in this Court pursuant to 28 U.S.C. § 1391 and 28 U.S.C. § 1400.
THE PLAINTIFFS
5. ArrivalStar S.A. is a corporation organized under the laws of Luxembourg, havingoffices located at 67 Rue Michel, Welter L-2730, Luxembourg. ArrivalStar is the authorizedlicensee of the patents alleged as being infringed in this lawsuit, with the right to sub-license the patents at issue.6. Melvino Technologies Limited is a corporation organized under the laws of theBritish Virgin Islands of Tortola, having offices located at P.O. Box 3174, Palm Chambers, 197Main Street, Road Town, Tortola, British Virgin Islands. Melvino owns all rights, title andinterests in the patents alleged as being infringed in this lawsuit.
THE PLAINTIFFS’ PATENTS
 
7. Plaintiffs own all right, title and interest in, and/or have standing to sue for 
infringement of United States Patent Number 6,714,859 (“the ‘859 patent”), entitled “System
and Method for an Advance Notification System for Monitoring and Reporting Proximity of a
Vehicle”, issued March 30, 2004. A copy of the ‘859
 patent is attached hereto as Exhibit 1.8. Plaintiffs own all right, title and interest in, and/or have standing to sue for 
infringement of United States Patent Number 6,952,645 (“the ‘645 patent”), entitled “System
and Method for Activation of an Advance Notification System for Monitoring and Reporting
Status of Vehicle Travel”, issued October 4, 2005. A copy of the ‘645 patent is attached hereto
as Exhibit 2.
 
3
9. Plaintiffs own all right, title and interest in, and/or have standing to sue for infringeme
nt of United States Patent Number 7,030,781 (“the ‘781 patent”), entitled“Notification System and Method that Informs a Party of Vehicle Delay”, issued April 18, 2006.A copy of the ‘781 patent is attached hereto as Exhibit 3.
 10. Plaintiffs own all right, title and interest in, and/or have standing to sue for 
infringement of United States Patent Number 7,400,970 (“the ‘970 patent”), entitled “System
and Method for an Advance Notification System for Monitoring and Reporting Proximity of a
Vehicle”, issued July 15, 2008. A copy of the ‘970 patent is attached hereto as Exhibit 4.
 11. Plaintiffs own all right, title and interest in, and/or have standing to sue for 
infringement of United States Patent Number 6,904,359 (“the ‘359 patent”), entitled“Notificat
ion System and Methods with User-Defineable Notifications Based Upon Occurrence
of Events”, issued June 7, 2005. A copy of the ‘359 patent is attached hereto as Exhibit 5.
 12. Plaintiffs own all right, title and interest in, and/or have standing to sue for 
infringement of United States Patent Number 6,486,801 (“the ‘801 patent”), entitled “BaseStation Apparatus and Method for Monitoring Travel of a Mobile Vehicle”, issued November 26, 2002. A copy of the ‘801 patent is attached hereto as Exhibit 6.
 THE DEFENDANT
13. Defendant TLX FREIGHT FOWARD, INC
. (“
TLX
”) is a
Delaware Corporationwith a principal place of business located at 350 5th Avenue, 59th Floor, New York, NY 10118.TLX transacts business and has, at a minimum, offered to provide and/or has provided tocustomers within this Judicial District and throughout the State of Florida services that infringe
claims of the ‘859, ‘645, ‘781, ‘970,
 
‘359 and ‘801 patents.
TLX is a part of a network with

You're Reading a Free Preview

Download
/*********** DO NOT ALTER ANYTHING BELOW THIS LINE ! ************/ var s_code=s.t();if(s_code)document.write(s_code)//-->